Title
Barles vs. Ponce Enrile
Case
G.R. No. L-12894
Decision Date
Jan 28, 1961
Illegitimate children sought paternity recognition from Alfonso Ponce Enrile; Supreme Court ruled action not prescribed, remanded for further proceedings.
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Case Digest (G.R. No. L-12894)

Facts:

  1. Parties Involved:

    • Plaintiffs: Lilia Juana Barles, Maria Estrella Barles, and Remedios Barles (illegitimate children of Alfonso Ponce Enrile and Genoveva Barles).
    • Defendant: Alfonso Ponce Enrile (alleged father).
  2. Nature of the Case:

    • The plaintiffs filed a petition for recognition of paternal filiation with a claim for moral damages.
    • They alleged that they were the illegitimate children of Alfonso Ponce Enrile, born out of his cohabitation with their mother, Genoveva Barles.
  3. Procedural History:

    • The case was initially filed in the Court of First Instance of Manila on September 1, 1955.
    • The defendant filed a motion to dismiss, arguing that the complaint did not state a cause of action and that the action had prescribed.
    • The court deferred action on the motion and proceeded to trial.
    • The case was later transferred to the Juvenile and Domestic Relations Court under Republic Act No. 1401.
    • On June 1, 1957, the Juvenile and Domestic Relations Court dismissed the complaint, holding that the action had prescribed.
    • Plaintiffs appealed directly to the Supreme Court.
  4. Key Allegations:

    • Plaintiffs sought judicial recognition of their paternity to establish their filiation with the defendant.
    • They argued that their action was authorized under Article 289 of the new Civil Code, which permits the investigation of paternity for illegitimate (spurious) children.

Issue:

  1. Primary Issue:

    • Whether the plaintiffs' action for recognition of paternity had prescribed under the applicable laws.
  2. Subsidiary Issues:

    • Whether the action for investigation of spurious paternity is governed by the same time limitations as the action for recognition of natural children under Article 285 of the new Civil Code.
    • Whether the plaintiffs' cause of action accrued from birth or from the time they could legally bring the action.

Ruling:

  1. Supreme Court Decision:

    • The Supreme Court reversed the decision of the Juvenile and Domestic Relations Court and remanded the case for further proceedings.
    • The Court held that the plaintiffs' action had not prescribed because it was filed during the lifetime of the presumed parent (Alfonso Ponce Enrile).
  2. Key Findings:

    • The action for investigation of spurious paternity is similar to the action for compulsory recognition of natural children under Article 285 of the new Civil Code.
    • Both actions are subject to the same time limitations, which require that the action be brought during the lifetime of the presumed parent, unless exceptions apply.
    • The plaintiffs' cause of action did not accrue from birth but from the time they could legally bring the action.
    • Articles 283, 284, and 289 of the new Civil Code, which govern the proof of illegitimate filiation, were given retroactive effect under Article 2263 of the same Code.

Ratio:

  1. Prescription of Actions:

    • The time for prescription of an action begins to run from the moment the right to commence the action comes into existence, not from the date of birth.
  2. Similarity Between Actions:

    • The action for investigation of spurious paternity is analogous to the action for recognition of natural children. Both actions aim to establish filiation and are subject to the same time limitations.
  3. Retroactive Application of Laws:

    • The provisions of the new Civil Code governing the investigation of paternity (Articles 283, 284, and 289) apply retroactively, even if the plaintiffs were born before the effectivity of the new Civil Code.
  4. Public Policy Considerations:

    • The time limitations for actions involving filiation are based on public policy, ensuring that such claims are resolved while the presumed parent is still alive and able to provide evidence.
  5. Denial of Motion for Reconsideration:

    • The Supreme Court denied the defendant's motion for reconsideration, reaffirming that the time limitation under Article 285 applies to both natural and spurious children.


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